HINCKS, Chief Judge.
Whether the penalty statute, 26 U.S.C.A. § 2707(a) is applicable to a case of non-compliance with the Withholding Act, 26 U.S.C.A. § 1621 et seq., is a question which I decided adversely to the plaintiffs for reasons stated in my preliminary memorandum and order of October 26, 1950, denying the plaintiffs' motion for judgment.
The "government", which for purposes of this memorandum may be taken as a comprehensive designation...
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